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2022 (7) TMI 1514 - ITAT DELHIIncome deemed to accrue or arise in India - Royalty receipts - taxability of the money received by the assessee from Indian customers for provision of Telecommunication connectivity services which included international private leased circuits, Multiprotocol Label Switching IP/VPN etc.- assessee is a company incorporated in Singapore engaged in the business of providing digital transmission of data through international private line or multi-protocol label switching etc. to facilitate high speed data connectivity - HELD THAT:- This controversy is now well settled by the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited [2021 (3) TMI 138 - SUPREME COURT] Respectfully following the findings of the coordinate Bench [2020 (10) TMI 604 - ITAT DELHI] for A.Y. 2011-12 and 2012-13, in the light of the decision of in the case of New Skies Satellite BV [2016 (2) TMI 415 - DELHI HIGH COURT] and Hon’ble Supreme Court (supra) we direct the AO to delete the impugned additions from both the assessment years. Decided in favour of assessee.
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